From: Nancy Schilreff [mailto:nschilreff@secureinvestmentmanagement.com] 

Sent: Friday, July 17, 2015 11:52 AM

To: EBSA, E-ORI - EBSA

Subject: RIN 1210-AB32

Senators and Statemen:

Let's look at the intent of the fixed and indexed annuities....they were built to PROTECT seniors 

from the variability of the Markets. They safety net of ZERO losses is huge for seniors because 

those losses may never be recovered or may not be recovered during the time they may need to 

access those funds. If those funds are not available to them, if they have been lost, due to market 

fluctuations, then they will become dependent upon Government funding for healthcare and 

essential elements of living.

The most DEVASTATING investment to retirees, is investing their IRA's into the Markets, in 

Variable Annuities or Mutual Funds (Variable Annuities are bundles of Mutual Funds packaged 

together). These. products have rules in place, by the SEC, stating that no more than 5% of the 

assets in Mutual Funds can, by law, be moved to Cash positions when Markets begin to 

faulter. In other words, there is NO SAFETY NET in these products, these products are 

designed to loose money when the Markets fall.

In Fixed and Indexed Annuities, there is never a downside when the Markets fall. And, many 

indexed annuities now have Lifetime Income Benefit Riders which offer a minimum of 6.5 - 8% 

annual growth, regardless of Market performance and they offer double income benefits for 

healthcare (without pre-qualifying.) During the year they decide to start their income, they are 

GUARANTEED their money will be there and that it will have grown, according to Market 

performance; on the other hand, they are GUARANTEED the 6.5-8% annual growth, in the 

event the Markets have not performed. This is a win-win-win for everyone - especially the 

senior.

Seniors or owners of Fixed or Indexed Annuities do NOT pay commissions to anyone. The 

commissions are a written agreement between the Insurance Company and the Agent, only. The 

commissions are not disclosed because the consumer does not pay them. Why should there be a 

concern about our commissions? You should weigh heavily on the hidden commissions and fees 

paid by the consumers, Seniors with IRA's in Variable Annuities and Mutual Funds. Those 

products could totally devastate estates of Seniors, in a flash. Those products carry devastation 

and ongoing, heavy commissions, payable during times of loss AND gains, by the consumer, 

Seniors (with IRAs). Those products could not and should not be recommended by Fiduciaries 

or Brokers to Seniors - they do not withstand the tests of "Suitability" or "Best Interests". And, 

those unsafe investments, should be under careful scutiny. Not only should they be prohibited in 

Retirement Accounts, all commissions should be stopped.

Please focus your concerns on the matters of EXTREME importance - those products that will be 

harmful or devastating to Seniors, Variable Annuities and Mutual Funds. Please do NOT focus 

your efforts on products that ARE in the BEST INTERESTS of Seniors, Fixed and Indexed 

Annuities. Commissions should not be a concern with Insurance Products because they are 

based on an agreement between the agent/advisor and the Insurance Company and they are NOT 
paid by the consumers. Your concerns should be on the on-going commissions PAID BY THE 

CONSUMER for products that are dubious to their lifelong well-being in retirement.

Nancy W Schilreff, PhD

Investment Advisor Representative

Secure Investment Management

865 Ebenezer Road

Knoxville, TN 37923

865.470.1171 - O

865.288.3300 - F

nschilreff@secureinvestmentmanagement.com

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